MARCH 2018
The Prince George Air Improvement Roundtable extends its sincerest gratitude to Dr. Peter L. Jackson for
his contributions to the roundtable and to the complex understanding of the Prince George airshed and its
components. Without his support and insight, this report would not be possible. Dr. Jackson’s support of
PGAIR extends beyond the members of the roundtable, to the broader community including the students
who directly benefit from his approach to hands-on learning. Thank you, Dr. Jackson.
Gail Roth is a valuable member of the PGAIR in her capacity as Air Quality Meteorologist with the Ministry
of Environment and Climate Change Strategy (ENV) in Prince George. Her commitment to the roundtable
is exceptional, as she goes above the demands of her role with ENV to support the roundtable and the
community in achieving its goals. Her input to this report was substantial, and very much appreciated. Thank
you, Ms. Roth.
The PGAIR Operations Committee members volunteer their time to PGAIR and provided valuable feedback
as well as historic knowledge to Phase 3 Plan Final Report. Thank you to all of the members of the Prince
George Air Improvement Roundtable Operations Committee.

The Prince George Air Improvement Roundtable (PGAIR) is a
volunteer planning group that evolved from the Airshed Technical
                                                                       Particulate Matter
Management Committee formed in 1995. PGAIR continues to
support the multi-jurisdictional nature of air quality management      Particulate matter is an air
in the airshed through its broad multi-stakeholder roundtable          pollutant that comes from
structure. It maintains a focused management effort on air quality     many different sources. It is
issues in Prince George.                                               most commonly measured
                                                                       according to its size. The two
The aim of this report is to communicate the results and
                                                                       most common size fractions
achievements of work undertaken in the Prince George airshed by
                                                                       are PM2.5 and PM10. Both
the Prince George Air Improvement Roundtable and its member
                                                                       of these size fractions are
agencies toward the improvement of air quality between 2011
                                                                       respirable, can be breathed
and 2016. The Phase 3 Implementation Plan (2011-2016) built
                                                                       deep into the lungs, and have
on the work carried out under Phases 1 and 2, and concentrated
                                                                       the potential to impact human
efforts towards reducing particulate matter (most specifically
                                                                       and environmental health.
PM2.5) from a variety of sources in the airshed.
Phase 3 targets aimed to:
• m
   aintain ambient PM2.5 concentrations equal to or more
  stringent than provincial, national and international ambient air
  quality objectives:
  • daily PM2.5 average not to exceed 25 µg/m3 by 2013;
  • a nnual average PM2.5 concentrations not to exceed 6 µg/m3 by
     2013 and 5 µg/m3 by 2016;
• r educe the amount of PM2.5 being released into the Prince George
   airshed from significant sources by 40% by 2016;
• r educe PM emissions in the Prince George airshed by
   implementing source-specific reduction strategies for 2011-2016
   and beyond.

The members of the roundtable recognized that meeting these
goals and implementing the key strategies would not be possible
without a combination of land use planning and voluntary,
educational and regulatory efforts. PGAIR served to coordinate
efforts and information sharing between member organizations.
It also served as the lead for research, public awareness and
educational initiatives. Member organizations focused efforts
on investigating and implementing actions relevant to each
of the key strategies. The results achieved under the Phase 3
Implementation Plan represent a co-operative effort by all sectors
and all members of the community.

                                                                       PHASE 3 PLAN FINAL REPORT        iii
Reviewing the outcomes of Phase 3 demonstrates              Many strategic efforts towards reducing PM2.5
notable successes, shortcomings, and highlights             emissions were implemented. Some notable
some of the challenges of airshed management in             highlights include the implementation of the City’s
Prince George. While none of the ambient PM2.5              Clean Air Bylaw, which saw early enforcement
targets were met every year,                                of restrictions on outdoor burning activities in the
• daily PM2.5 concentrations remained at or below 25       city; the coordination of the Provincial Woodstove
   µg/m3 for an average of 360.17 days per year over        Exchange Program at the local and Regional District
   the 2011-2016 period, and                                level; and ongoing communication with the public
                                                            about the impacts of local and regional air quality
• a nnual average PM2.5 concentrations were at or
                                                            events, alongside strategic partners such as the
   below 6 µg/m3 for four out of the six years.
                                                            Ministry of Environment and Climate Change
Even more, a detailed evaluation of ambient PM2.5           Strategy and the Northern Health Authority. Perhaps
concentrations and trends revealed that significant,        the largest improvement in PM emissions can be
measureable reductions of PM2.5 have been realized          attributed to technology upgrades by industrial
in the city, particularly for the heavy industrial sector   partners.
situated to the east of downtown (Jackson et al.,           Overall, PGAIR worked to implement strategies
2017). This same evaluation identified that the Phase       outlined in the Phase 3 Implementation Plan through
3 goals were quite rigid and did not account for the        developed networks and partnerships. Progress
‘unmanageable’ component of PM2.5 (e.g. naturally           was made on nearly every identified strategy, and of
existing sources and external influences such as            course, some areas saw more success than others.
forest fire smoke). It was also highlighted that            Most of the strategies are long-term in their scope
future goals will need to consider recent changes           and results are difficult to quantify. The greatest
to monitoring technology that now measures PM2.5            success by PGAIR, however, is in the engagement
concentration more completely. Recommendations              of the overall community, which includes residents,
regarding these factors outlined in the report will be      businesses and industry, and government at all
considered for future goal setting.                         levels. This community connection will be critical in
Research conducted in Phases 1 and 2 identified             the move forward into the next phase.
several major sources that contribute PM2.5                 PGAIR is guided in the next phase by the Strategic
emissions from within the Prince George airshed             Plan (2017-2021), which builds on successes of
including permitted and non-permitted industry,             working together at the local level and encourages
commercial activities, dust, transportation and             further improvements across all sectors. The
wood burning. Some of these emission sources                Strategic Plan recognizes that further work is
are particularly challenging to address: they are not       needed to continue to reduce PM emissions
regulated, and they are distributed across the city`s       across all sectors to ensure a long-term healthy and
landscape, making them impractical to measure on            sustainable community. PM will remain as a priority
a regular basis. For this reason, the overall success       for PGAIR since research clearly demonstrates
of the 40% emissions reduction target is difficult          its association with negative health outcomes
to quantify. Residential heating and wood burning           for exposed populations (Brook et al. 2010).
remain important areas for improvement, and                 Future planning will also include a review of other
strategies to reduce these include education and            pollutants, which will be considered for inclusion in
outreach as major components.                               air quality management activities under the 2016-
As a partial indicator, air emissions data available        2021 Strategic Plan.
from permitted industries (collected by ENV) was
reviewed. Major point sources of PM (e.g. large
industrial stacks) show a substantial decrease in
emissions over time. This trend corresponds with
the findings of the Jackson et al. (2017) evaluation.

Table of Contents                                         List of Figures
Acknowledgements                                    ii    Figure 1: PGAIR organizational structure, with              3
                                                          secretariat support from the Fraser Basin Council, and
Executive Summary                                   iii   input from the Monitoring Working Group.
1.0 Introduction                                    1
                                                          Figure 2: Timeline for development of air quality           5
2.0 Background                                      1     measures and the creation of PGAIR

2.1 Air Quality Trends in Prince George             1     Figure 3: Comparison of PMF and CMB source                  7
                                                          contributions. Average is the overall average (all
3.0 Air Quality Management in Prince George         2
                                                          data), High Mass is the days when highest 20%
3.1 Prince George Air Improvement Roundtable (PGAIR) 2    of PM2.5 samples were collected; Winter days, and
                                                          Summer days represent samples collected during
2.3 Phase 1 (1998-2006) and Phase 2 (2006-2010)     4     each of those respective seasons (Sonoma, 2008).
2.4 Phase 1 and 2 Achievements                      5
                                                          Figure 4: Contributions by Source Category to               8
2.4.1 Chemical Speciation Study                     5     Predicted Annual Averaged PM2.5 Concentrations at
                                                          the Plaza Site: 2003 – 2005 (Stantec, 2010).
2.4.2 Dispersion Model study                        7
                                                          Figure 5: Number of days with 24h PM2.5 > 25 µg/m3          14
3.0 Phase 3 Plan (2011-2016)                        8
                                                          (Jackson et al, 2017)
3.1 Phase 3 Priorities and Strategies               8
                                                          Figure 6: Deseasonalized monthly PM2.5                      15
3.2 Phase 3 Targets                                 11    concentrations (µg/m3) at Plaza 400 from 2005-2016
                                                          for a) mean, and b) 98th percentile. [Jackson et al,
4.0 Phase 3 implementation plan Evaluation          12
                                                          2017]. Deseasonalizing data provides a ‘clearer’ look
4.1 Short-term Goals                                12    at the PM2.5 trends without seasonal influences due
                                                          to the weather.
4.2 Long-term Goals                                 14
                                                          Figure 7: Annual average concentrations of PM2.5 at         16
4.3 The 40% Aspirational Target                     17
                                                          Plaza 400, with PM concentration on the left axis, and
4.4 Achievements by Category                        20    wind speed on the right. [Jackson et al., 2017]

4.4.1 Dust                                          20    Figure 8: Deseasonalized monthly average PM2.5              17
                                                          concentrations at Plaza 400 from 2005-2016 for 8
4.4.2 Permitted Emissions                           20
                                                          wind directions. The centre rose diagram shows
4.4.3 Non-Permitted Industry & Commercial           21    the proportion of each wind direction and PM2.5
                                                          concentration contributes to the mean. [Jackson et
4.4.4 Transportation Emissions                      21    al, 2017]
4.4.5 Wood-burning                                  21
                                                          Figure 9: Relative reductions in point source
4.4.6 Research, Education and Coordination          22    contributions (source: ENV)

5.0 Conclusion and Next Steps                       23
References                                          25
                                                          List of Tables
Appendix A: Phase 3 Implementation Plan             27    Table 1: Comparison of PMF and CMB source                   6
                                                          contributions. Average is the overall average (all data);
Appendix B: Member Actions and Achievements         28    High Mass Days are the days on which the highest
                                                          20% of PM2.5 samples were collected. Winter and
Appendix C: Prince George Air Quality Monitoring    29
                                                          Summer represent samples collected during each of
                                                          the respective seasons (Sonoma, 2008).

                                                                               PHASE 3 PLAN FINAL REPORT              v
1.0 INTRODUCTION                                2.0 BACKGROUND
Particulate matter (PM) has been a
                                                2.1 AIR QUALITY TRENDS IN PRINCE GEORGE
significant air quality issue in the Prince
George airshed since at least the 1980s,        An airshed is known as an area where the movement of air
and has been monitored as PM10 and              is restricted by geographic features and by weather patterns
PM2.5 since 1992. Exposure to PM,               [B.C. Airsheds,online, December 2017]. Prince George’s
especially the finer fraction such as PM2.5     airshed is strongly affected by its location at the confluence
is linked to a wide variety of human            of two large rivers: the Nechako River and the Fraser River.
health impacts, including acute respiratory     Their river valleys form a large depression that is occupied
symptoms, chronic bronchitis, decreased         by the main developed part of the city known as the ‘bowl’
lung function, cardiovascular disease and       area. Residential and industrial development, as well as the
premature death. (Kim et al. 2015)              Prince George Airport, characterizes the upland parts of the
                                                city. Beyond the city’s developed boundaries is forest and
Actions taken under the Prince George           agricultural land, along with rural residential properties.
Air Quality Management Plan (Phases 1
and 2) since 1995 to reduce fine PM in          Prince George is subject to a variety of factors that can
the Prince George airshed have been met         combine to create air quality problems in the airshed.
with some success, achieving reductions         Prince George has numerous pollutant sources within its
in the coarser fraction (PM2.5-10) through      boundaries, such as heavy industry, (including the pulp
measures such as road dust sweeping             and paper industry and the petroleum refining industry),
programs and the application of coarser         residential heating and wood smoke, road dust and
winter traction material. Improvements          transportation emissions. Combined with frequent light
in PM2.5 levels have been slower, with a        winds and wintertime thermal inversions, these conspire
downward trend emerging.                        with valley terrain to trap pollutants where a high density of
                                                people live and work.
This is the final report of the Phase 3 Plan,
which builds on management actions              In addition to those sources located within the city’s
identified in Phases 1 and 2. The focus         boundaries, Prince George has been subject to external
of the community air quality targets is         sources of pollutants from wildfires. High levels of
reducing PM2.5 emissions, and this is           particulate matter from wildfire smoke can represent a
reflected in the management actions taken       significant contribution to Prince George’s airshed in a given
during Phase 3. This report will summarize      year, depending on a variety of factors including winter
current air quality trends, outline             snow pack and spring and summer weather patterns.
successes achieved during the Phase 3           Several pollutants types are monitored throughout the
Plan, and outline the future direction for      Prince George airshed in order to supply information to
work to be done in the airshed by PGAIR,        Provincial government, local governments, stakeholders,
its member agencies and the residents of        and members of the public for the purpose of responding
Prince George.                                  to changes or threats. This air quality data collection is
                                                carried out by a network of air quality monitors operated
                                                by the Ambient Air Quality Monitoring Working Group in
                                                collaboration with the Ministry of Environment and Climate
                                                Change Strategy (ENV). For more information about the
                                                group, see Appendix C. Many communities also support
                                                an air quality management committee or task force aimed
                                                at bringing stakeholders together in a roundtable format,
                                                where each member has an equal opportunity for input.
                                                In Prince George, the Prince George Air Improvement
                                                Roundtable fulfills this community-based function.

Since 1995, air quality management in the Prince George airshed has been coordinated through a
community-based, multi-stakeholder group – now a non-profit society known as the Prince George Air
Improvement Roundtable (PGAIR) – comprised of representatives (largely volunteers) from provincial,
municipal and regional governments, Northern Health, industry, business and community groups, the public,
and the University of Northern BC.
The current membership and structure of PGAIR is illustrated in Figure 1. The Fraser Basin Council provides
secretariat support to PGAIR. The Ambient Air Quality Monitoring Working Group is an arms-length body,
made up of members from the industrial sector whose emissions contribute significantly to pollutant levels
in the airshed. Their financial contributions support the air quality monitoring network in Prince George, and
provide data to PGAIR towards managing goals and targets (see Appendix C for more information).

Figure 1: PGAIR organizational structure, with secretariat support from the Fraser Basin Council, and input from the
Monitoring Working Group.

                                                                                     PHASE 3 PLAN FINAL REPORT         2
Membership in PGAIR is described in the                                    3.2 PHASE 1 (1998-2006) AND PHASE 2
certificate and bylaws of the society, governed                            (2006-2010)
by the BC Societies Act (2016), and was
originally defined by the Prince George                                    The Phase 1 Plan, adopted in 1998, identified
Airshed Technical Committee in their Phase                                 measures to improve local air quality. In particular, it
1 Management Plan report (1998). PGAIR is                                  set out 28 recommendations for actions to reduce
not a regulatory body and has no jurisdiction                              and manage sources of fine PM, including industrial
over air quality. Instead, PGAIR is responsible,                           emissions, road dust, and residential activities such
through consensus-based and science-based                                  as old wood burning appliances and open burning.
decision making,1 for developing and (in part)                             The Plan also addressed land use planning, poor air
implementing the Prince George Air Quality                                 quality episode management, and monitoring and
Management Plan (Plan).2 The Plan sets                                     research requirements for measuring progress and
out recommendations for voluntary actions                                  identifying future management needs. The Phase 1
intended to help improve local air quality, in                             Plan achieved results in a number of areas, including
particular, to achieve and maintain acceptable                             the phasing out of beehive burners, the upgrading of
air quality by reducing the emission of those                              some pollution control equipment at area pulp mills,
air contaminants that are causing unacceptable                             and the enactment of the City of Prince George
air quality, and to prevent future air quality                             Clean Air Bylaw.
problems from developing.                                                  To continue efforts at improving air quality in Prince
 evelopment and implementation of the Phase 1,
D                                                                          George, the Phase 2 Plan was developed in 2006.
Phase 2, and Phase 3 Management Plans were                                 The Phase 2 Plan represents the bridge between
guided by the following principles:                                        Phase 1 – the completion of the source modeling
                                                                           (dispersion model) study being conducted by the
• A
   cceptable air quality is everyone’s
  right; protecting air quality is everyone’s                              PGAIR Research Working Group (RWG) – and
  responsibility;                                                          Phase 3, which prioritized PM2.5 emission sources
                                                                           for reduction based on the results of this and other
• A
   cceptable air quality is an important                                  research, including a chemical speciation study
  contributor to a healthy community and a
                                                                           and the dispersion modelling study. Achievements
  sustainable economy;
                                                                           resulting from work carried out under the Phase 1
• A
   chieving acceptable air quality requires that                          and 2 Plans are significant and represent promising
  local, provincial and, federal government                                signs that management actions undertaken to
  agencies work together. Public and industry                              reduce odour (TRS), PM10 and PM2.5 have had
  commitment to meeting targets is also                                    a positive effect on air quality within the Prince
  necessary.                                                               George airshed.
                                                                           In 2008, at the start of the Phase 2 Air Quality
                                                                           Management Plan, PM2.5 concentrations were
  The use of scientific results as a basis for decision-making to          declining relative to previous years. However,
implement effective airshed management plans is enshrined in the           PM2.5 concentrations in Prince George were still
PGAIR constitution (section 2(c)); similarly, the use of consensus-based
decision making is enshrined in the PGAIR bylaws (Part 12) Consensus
                                                                           high when compared to other monitored locations
is defined as “a general agreement by all directors or members, as         across British Columbia (ENV 2008, p28). By Phase
the case may be, or the lack of expressed objection by a director or       3 (2011), further reductions of PM2.5 were observed
member, as the case may be” (section 59).                                  and annual average concentrations had dropped
  An air quality management plan provides a non-legal blueprint for        from 2nd to 6th highest across the province (ENV
managing community development and controlling all air pollution           2011, pp 22, 26-27, 85), although the overall trend
sources within an airshed, and allows the community to focus on those      between 2008 and 2011 was unclear. See Figure
pollutants or issues most important to the community.
                                                                           2 for the timeline of developments for PGAIR and
                                                                           measures to improve Prince George air quality.

1995 - Prince George
                      Airshed Technical                 Formalization of air      Prince George Air Quality
                                                        quality management        Management Background
                        Management                             process                     Report

                    1998- Establishment of
                     Airshed Management
                                                        Collaborative multi-            Would later become
                    Steering Committee, Air           jurisdictional committee                PGAIR
                    Quality Implementation

                      Phase 1 Air Quality             Progress Report - June 28     Elimination of beehive
                      Management Plan                           2004                 burners from airshed

                                                                                  Speciation and Dispersion
                      Phase 2 Air Quality                                         Modelling studies provide
                                                        Accepted June 2006         air emissions inventory
                      Management Plan                                                and identifies top 5

                       Prince George Air
                         Improvement                        August 2008
                                                                                   Sets ambitious targets for
                      Roundtable (PGAIR)                                                PM2.5 reductions

                                                                                     Regulates sweeping
                     City of Prince George                 amended 2010
                                                                                   activities, prohibits open
                        Clean Air Bylaw                                            burning and limits use of
                                                                                   wood-burning appliances

                           Phase 3
                                                                                    Significant improvement
                     Implementation Plan                  January 1, 2012
                                                                                   in ambient levels of PM2.5

                     2017-2021 Strategic

Figure 2: Timeline for development of air quality measures and the creation of PGAIR.

                                                                                    PHASE 3 PLAN FINAL REPORT   4
    Reconciliation of Sonoma                Two significant studies were completed during Phase 2.
    and Stantec studies                     A chemical speciation study and a dispersion modeling study
    Based on the findings of                were carried out to identify relative contributions of sources of
    the dispersion model study,             PM10 and PM2.5 in the airshed. The results of this research, briefly
    there were some areas of                described below, helped set the goals and targets under the Phase
    disagreement between it                 3 Implementation Plan.
    and the chemical speciation
                                            3.3.1 Chemical Speciation Study
    study in terms of identifying
    the major sources of fine               A chemical speciation study, which identified the contributions from
    PM in the Prince George                 major contributors of PM2.55 to the airshed at the Plaza site, was
    airshed. As such, a critical            completed by Sonoma Technology, Inc. in 2008.3
    step in prioritizing sources            This study used a particular type of source apportionment, known
    for reduction under the                 as receptor modeling, to identify the relative contributions of
    Phase III Plan was to                   different PM2.5 emission sources in the Prince George airshed.
    reconcile, to the extent                Between December 2004 and March 2006, data (138 24-hour
    possible, the major findings            PM2.5 filter samples) were collected at the Plaza 400 site. The
    and recommendations of the              data (filter samples) were analysed and examined for chemical
    research studies.                       signatures, which identified the PM2.5 sources by comparing them
    The comparison and                      with chemistry samples from local sources or similar source types.
    reconciliation was carried              The data were examined using two different analytical approaches,
    out by members of                       chemical mass balance (CMB) and positive matrix factorization
    the Research Working                    (PMF). Comparing the results of both methods provided insight
    Group with expertise in                 into which sources were clearly identified (i.e. results from both
    chemical speciation and/                methods agreed), and which were less certain (i.e. the methods
    or dispersion modeling,                 produced dissimilar or weakly agreeing results).
    and recommendations                     The findings of this study indicate that, on average, three major
    were made to PG                         sources contribute generally equal amounts of PM2.5 to the Plaza
    AIR for consideration                   site (see Table 1 and Figure 3):
    and incorporation into
                                            • Pulp mill emissions (24-25%);
    management actions.
                                            • Wood-burning emissions (18-26%);
                                            • Mobile (including vehicle) emissions (22-24%).

                                                Source Apportionment of PM2.5 in Prince George, British Columbia (Sonoma, 2008).

Table 1: Comparison of PMF and CMB source contributions. Average is the overall average (all data); High Mass Days are
the days on which the highest 20% of PM2.5 samples were collected. Winter and Summer represent samples collected
during each of the respective seasons (Sonoma, 2008).

Figure 3: Comparison of PMF
                                                                          and CMB source contributions.
                                                                          Average is the overall average
                                                                          (all data), High Mass is the
                                                                          days when highest 20% of
                                                                          PM2.5 samples were collected;
                                                                          Winter days, and Summer days
                                                                          represent samples collected
                                                                          during each of those respective
                                                                          seasons (Sonoma, 2008).

3.3.2 Dispersion Model study
An emissions inventory and dispersion model study was started in        PM2.5
2006 by researchers at UNBC together with the PGAIR Research            Particulate matter less than
Working Group (RWG). The study included an extensive micro-             2.5 microns in diameter
emissions inventory that identified all sources of respirable PM        (PM2.5), about 1/30th the
(PM10 and PM2.5) in the Prince George airshed and used the              size of a human hair most
CALMET/ CALPUFF computer model to predict the contribution              strongly correlates with
of each source to ground-level (ambient) fine PM concentrations         negative health effects
for the years 2003 to 2005. While the chemical speciation study         (relative to larger particle
(described above) provided valuable initial insight about the           sizes). Health impacts
particulate matter profile in the airshed, the dispersion model study   to the respiratory and
was a necessary component to provide much more detailed and             cardiovascular system have
specific information about sources of particulate matter and how        been clearly demonstrated
they are transported throughout the community. This additional          by research although several
information was needed to thoroughly support the development of         other effects are also being
the Phase 3 Air Quality Implementation Plan.                            studied.
An interim report was produced in April 2009 and the general            Sources of PM2.5 that are
results shared with PGAIR and the public. In the summer of 2009,        generated by human activity
the interim report underwent an extensive technical review (of all      include vehicle emissions,
inputs, assumptions and settings used in the study) by an external      industrial emissions, and
party (RWDI Air Inc.), increasing confidence in the results among all   other combustion sources
stakeholders and the public. Approximately 140 recommendations          like burning wood or coal for
were made, largely to correct minor errors and improve                  heat. Of course there are
assumptions used in the interim report. These recommendations           natural sources as well, such
were reviewed by the RWG and additional recommendations made            as smoke from wildfires.
for remodelling and revision.

                                                                        PHASE 3 PLAN FINAL REPORT           6
Stantec Consulting Ltd. was selected in the fall of 2009 to carry out the recommended remodelling and
revision of the study. They produced a final report received by PGAIR and the Ministry of Environment (ENV)
at the end of March 20104. The report was formally adopted in April 2010 following reviews by the ENV and
the PGAIR Research Working Group.
While the dispersion modeling study provided much more information than discussed here, summary results
of the emissions sources are highlighted to demonstrate the type of information that was used to support
the selection of the Phase 3 priorities.
The top four major contributors to PM2.5 at the Plaza site (2003-2005 annual average) were identified as
• Permitted users (industry) (18%);
• On-road dust (mobile sources) (18%);
• Locomotive sources (11%);
• Commercial restaurants (11%).

A breakdown of the contributions (Stantec, 2010) by source category to predicted annual averaged PM2.5
concentrations at the Plaza site, 2003 – 2005, is provided below in Figure 4.

    Prince George Air Quality: Dispersion Model Study – A Revision (Final Report) (Stantec, 2010).

Figure 4: Contributions by Source Category to Predicted Annual Averaged PM2.5 Concentrations at the Plaza Site:
2003 – 2005 (Stantec, 2010).

4.0 PHASE 3 PLAN (2011-2016)
Based on the results of research carried out in Phase 2, the              Waste Discharge
Phase 3 Plan prioritized significant PM2.5 sources for emissions          Regulation
reduction. The studies described in Section 2.4 identified that           Most activities that discharge
all major sources or sectors in the Prince George airshed were            pollutants into the air require
significant contributors to local particulate matter pollution. PGAIR     an authorization or permit.
has developed recommendations and management actions under                The Waste Discharge
the Phase 3 Plan for each source/sector. Some management                  Regulation (WDR) defines
actions were carried out by PGAIR, but many were, and remain,             what industries, activities,
the responsibility of member agencies and community members.              and operations require
Although the main focus of reduction efforts was PM2.5, reducing          authorizations to discharge
other pollutants such as dust (PM10) was also supported in the            or release waste to the air,
implementation plan and strategies. The following sources or              water, and land under the
sectors were included in the Phase 3 Implementation Plan, in              Environmental Management
addition to Research Education and Coordination activities (see           Act (EMA) in B.C.. Some
Appendix A):                                                              examples of industries whose
• Permitted Industry                                                      activities may be affected by
• Dust                                                                    the WDR include pulp and
                                                                          paper mills, wood processing
• Non-Permitted Industry & Commercial                                     facilities and petroleum
• Transportation (mobile)                                                 processing facilities.
• Wood burning
• Background (naturally occurring)
• Other Sources

Open burning was included where applicable in the above
categories. For example, residential recreational fires and residential
land debris burning would be captured in the residential sector.

Permitted Industry
For the purpose of the Phase 3 Plan, the industrial sector
includes all small and large industry that contributes PM or other
identified pollutants to the airshed. These industries may hold air
discharge permits or be required to follow a regulation under the
Environmental Management Act to release air emissions. This
includes such industries as, but not limited to:
• Pulp and paper
• Oil refinery
• Sawmills
• Pellet plants
• Asphalt plants
• Chemical plants

                                                                          PHASE 3 PLAN FINAL REPORT         8
Dust                                               Woodburning, (or Residential Heating)
Although dust is often considered part of the      The residential category includes all residents living in
larger particulate size category dust emissions    the Prince George airshed. PGAIR recognises that this
contain a significant component of smaller         particular category is far reaching and includes several
invisible particles (PM2.5). Dust sources mainly   recommendations, most of which require ongoing
include “fugitive” (wind-blown dust from           education and awareness of residential practices that can
open areas), on-road and off-road vehicle use,     contribute to fine PM emissions in the airshed. Some
unswept parking lots, and industrial yards.        examples of residential practices or equipment that have
                                                   been recognized by PGAIR to contribute to fine PM in the
Non-Permitted Industry and Commercial              airshed include, but are not limited to:
Non-permitted industry and commercial              • W
                                                      ood-burning appliances (e.g. poor wood burning
businesses were identified as any commercial         practices, inefficient non-certified wood burning
operation that contributes to fine PM and            appliances)
or other identified pollutants to the airshed.
                                                   • O
                                                      pen burning (recreational fires to larger burns,as defined
In many cases, air emissions from these              in the City of Prince George Clean Air Bylaw # 8266)
sources are unregulated. Examples of
commercial businesses and associated               • Vehicle idling
sources of emissions include, but are not          • F
                                                      ugitive dust (e.g. dust created by off-road vehicles, on-
limited to:                                          road fugitive dust created by poor driving practices, yard
• Restaurants                                        maintenance practices that create fugitive dust)

• Auto-body shops                                  • S
                                                      mall equipment (e.g. barbeques, lawn mowers, leaf
                                                     blowers, snow blowers, and four stoke engines)
• Scrap and salvage yards
• Tire retreading facilities                       Research, Education and Coordination
• Parking lots                                     Phase 3 recognizes research, education and coordination
• Agricultural burning                             as critical activities that inform and support management
                                                   actions of the plan. Goals and targets that are informed
• B
   usinesses that primarily use wood and/or oil
                                                   about air quality conditions, trends and contributing
  for space heating purposes
                                                   sources in the airshed are measurable and therefore
                                                   more achievable. They are also the mechanism by which
Transportation                                     less understood or emerging topics can be identified
The transportation sector encompasses any          and investigated in more detail. Upon completion of
transportation operation that contributes to       each research project, new management actions may be
fine PM pollution in the airshed. Examples of      developed and incorporated into management actions and
transportation include, but are not limited to:    plans. PGAIR plays an important role in the coordination
• Fleet vehicles                                   of member efforts and is instrumental in reaching out to
                                                   the public and stakeholders about actions to improve air
• Rail transportation                              quality.
• Off-road vehicles
                                                   In order to meet the targets set in the Phase 3 Plan,
• Equipment and machinery                          PGAIR adopted key strategies to support actions in
• Light and heavy duty vehicles                    several important areas: industrial emissions, research
                                                   and education, transportation, wood burning, dust control,
• Individual personal vehicles
                                                   and vehicle emissions. These key strategies are designed
• Buses                                            to support source-specific responses and potential
• C
   ommercial businesses involved in               actions for implementation over the life of the Phase 3
  transportation                                   Implementation Plan and beyond (see Appendix A).

Key Strategies
• C
   ollaborate with PGAIR member organizations to develop policies that reduce air quality impacts from new or
  expanding industries (e.g. identify lands outside the airshed for industry), and provide feedback to industry to
  encourage the use of best practices and technology to reduce emissions.
• T
   hrough research and education, increase public understanding of air quality issues, advisories, potential
  solutions, and success stories.
• E
   stablish a PGAIR awards and recognition program to recognize achievements to improve air quality by local
• C
   ollaborate with the transportation sector to reduce emissions through best practices and technology, and
  through improved transportation planning and infrastructure.
• R
   educe emissions from wood-burning heating systems and backyard recreation fires by encouraging woodstove
  upgrades to EPA/CSA certified models through the Provincial Woodstove Exchange Program, increasing
  knowledge of proper burning practices and increasing awareness of the City’s Clean Air Bylaw.
• R
   educe dust by encouraging more paving, improved street and private lot sweeping, appropriate off-road use,
  and improved residential yard maintenance.
• R
   educe vehicle emissions by encouraging more alternative transportation such as biking, transit and
  carpooling, and improved traffic low, less idling, and more efficient fleet movement. PGAIR may also work with
  stakeholders to help establish local vehicle emission testing requirements similar to other jurisdictions.

The Prince George Air Improvement Roundtable committed to focussing efforts on all particulate matter
sources to voluntarily reduce particulate emissions (PM10 and PM2.5) that are shown (by modeling and other
studies) to have a significant impact on local ambient air quality. Since the PM2.5 fraction (smallest particles)
represents the greatest known risk to health (Brook et al. 2010), two- and five-year targets were set for this
The two-year ambitious ambient air quality targets to be achieved by December 31, 2013:
• 24-hour average not to exceed 25 µg/m3; and
• an annual average of 6 µg/m3 (equivalent to the Province’s PM2.5 planning goal).

The five-year target stated that by December 31, 2016, the following should be achieved:
• an aspirational target of a 40% reduction on all significant emission sources; and
• an annual average PM2.5 ambient target of 5 µg/m3.

The goals set by the PGAIR Board of Directors can be thought of as ways to evaluate acute (short-term) and
chronic (long-term) exposure to air pollution. The PGAIR’s goals related to ambient air quality are organized
below according to these concepts.
Goals that consider air quality over short durations of time evaluate acute (short-term) impacts, for example,
the number of days that approached or exceeded the 24-hour PM2.5 objective. These short-term periods of
poor air quality commonly occur on days when a temperature inversion traps pollutants in the “bowl” area of
Prince George, or when wildfires during summer months cause smoky conditions locally.
Goals that consider longer periods of time, such as over the course of a given year, consider chronic
(long-term) impacts. The annual average takes into account all of the short-term episodes and their
magnitudes combined.
Goals that address both types of impacts are important for considering the overall impact of air quality on
residents and the community.

                                                                                PHASE 3 PLAN FINAL REPORT            10
                                     PLAN EVALUATION
                                     The Prince George Air Improvement Roundtable has made great
     Change in Monitoring            progress toward improving air quality for all residents in the
     Technology                      Prince George airshed. Through the combined efforts of member
                                     agencies and individual residents, significant achievements can be
     The technology used to          recognized. Despite these achievements, significant work remains
     measure PM2.5 changed in        for continued improvement to be realized, particularly on non-
     2013. The old technology        permitted sources such as residential or individual contributions.
     (TEOM) heated the sample,
     which caused semi-volatile      The University of Northern British Columbia (UNBC) conducted an
     compounds within the            analysis for PGAIR to evaluate if the Phase 3 goals tied to ambient
     sample to evaporate (and        air quality were achieved. Students of the 2017 ENSC 412 class
     would not be measured).         completed the analysis under the support and advisement of
     The new technology              their professor, Dr. Peter Jackson. The key findings of this work
     (SHARP) is able to better       are presented below. The full report can be read in the Natural
     capture the semi-volatile       Resources and Environmental Science Extension Note series
     compounds within the            [Jackson et al. 2017].
     sample. As a result, SHARP      5.1 DAILY AIR QUALITY TARGETS
     analyzers tend to measure
     higher PM2.5 concentrations     In 2011, the target set by PGAIR was a daily limit of not more than
     on average than TEOMs.          25 µg/m3 (24-hour average Provincial PM2.5 Objective). This goal
                                     suggests that should any day out of 365 exceed 25 µg/m3, the
                                     target would not be met.
                                     The 24-hour Provincial Air Quality Objective (AQO) of 25 µg/m3 is
                                     considered to be achieved if it is met at the 98th percentile of daily
                                     average over one year. By this definition, PGAIR’s goal could be
                                     considered met, however the goal was not stated in these terms.

                                     Goal: 24-hour average not to exceed 25 µg/m3
                                     Daily PM2.5 concentrations were at or below 25 µg/m3 for an
                                     average of 360.17 days per year over the 2011-2016 period. While
                                     exceedances did occur, the frequency was less than 5 days on
                                     average each year (see Figure 5) [Jackson et al 2017].
                                     The data clearly demonstrate that the number of days per year
                                     that exceeded the PM2.5 limit has declined since the beginning
                                     of air quality management activities in the late 1990s. PM2.5
                                     concentrations between 2011 and 2016 are historically low with the
                                     exception of 2014 when wildfire smoke contributed to more than
                                     half of exceedances that year [ENV 2016].
                                     The daily PGAIR target may have been overly stringent in the
                                     sense that allowances for impacts from unmanageable sources
                                     (such as wildfires) were not explicitly incorporated. Other than
                                     wildfire impacts, exceedances most frequently occurred during
                                     the cooler months of the year (late fall, winter and early spring).
                                     This trend is heavily driven by the weather during these months.
                                     When daylight hours are shorter and temperatures are colder, the

atmosphere tends to be more stable and becomes less effective at dispersing pollutants. For this reason,
the same amount of pollutants in the atmosphere during the summer does not result in the higher pollutant
concentrations experienced in the winter. However, with the addition of pollutants such as residential wood
smoke contributing more during cooler months of the year on top of pollutants present all year (e.g. traffic,
industry), avoiding daily exceedances becomes increasingly challenging to achieve.
Prince George’s airshed is subject to particulate matter contributions from a variety of sources, and because
of its location in a river valley, managing air quality is likely to be an ongoing process. In the face of climate
change, the changing forest fire regime is expected to become increasingly important with regards to air
quality impacts in Prince George (along with other BC communities).

Figure 5: Number of days with 24h PM2.5 > 25 µg/m3 (Jackson et al, 2017)

                                                                               PHASE 3 PLAN FINAL REPORT         12
Goal: an annual average PM2.5 ambient target of 5 µg/m3
Examining the longer-term trends yields some good news. Jackson et al. (2017) found that the airshed
experienced a downward trend in annual average concentrations of PM2.5 in Prince George at Plaza 400 over
the Phase 3 period (see Figure 6), and longer. This trend continues from 2005, the baseline year used in the
dispersion modelling research (Phase 2). In fact, there has been a continuous improvement in the annual
mean concentration of PM2.5 from 2005 to 2016, continuing the trend of yearly decreases in the mean annual
concentration since the beginning of the air quality management planning process [Jackson et al 2017].

Figure 6: Deseasonalized monthly PM2.5 concentrations (µg/m3) at Plaza 400 from 2005-2016 for a) mean, and b) 98th
percentile [Jackson et al, 2017]. Deseasonalizing data provides a ‘clearer’ look at the PM2.5 trends without seasonal
influences due to the weather.

While overall decreasing PM2.5 trends (see Figure 6) demonstrate alignment with PGAIR’s 2016 goal of
meeting an annual average concentration of PM2.5 of 5 µg/m3, the target was met only in one year, 2011
(see Figure 7).
The analysis estimated that background emissions account for 18-35% of the annual average which equates
to 1-3 µg/m3 based on measurements collected at the downtown (Plaza 400) monitoring station. This means
that the manageable component of the PGAIR annual goal (5 µg/m3) is reduced to 2-4 µg/m3. Given the
strong influences of meteorology on PM2.5 concentrations during the cool weather months (as described
above), the 5 µg/m3 would be incredibly difficult and could be considered unreasonable to attain.
The manageability of the ‘background’ portion of the ambient emissions will need to be considered in future
goal setting. Setting future goals that take a minimum or acceptable number of exceedances into account
would be a more reasonable approach.

Figure 7: Annual average
                                                                               concentrations of PM2.5 at Plaza
                                                                               400, with PM concentration on
                                                                               the left axis, and wind speed
                                                                               on the right [Jackson et al.,

Looking at annual concentrations of PM2.5 tells the general air quality
story. However, a closer look can help us answer more detailed            Background vs.
questions such as which areas in the community are experiencing           manageable emissions
the biggest change in emissions. One way to answer this question
is to look at where the PM2.5 emissions are coming from. When             The idea of background
meteorological data is examined (wind direction and speed) and is         emissions refers to the
coupled with PM2.5 measurements, a picture can be formed of how           ambient concentrations of
much PM2.5 is coming from each direction. The windrose displayed          pollutants from natural and
in the centre panel of Figure 8 shows the relative contribution of        anthropogenic sources that
PM2.5 emissions by direction. It demonstrates that a significant          originate outside of the
proportion of the annual concentration measured at the downtown           airshed’s boundaries, and are
(Plaza 400) station comes from east of the city, which is a heavily       transported into the airshed.
industrialized area. The panels surrounding the plot show trends of       Air quality management relies
PM2.5 over time for eight wind sectors (northeast, north, northwest,      on the ability to distinguish
west, southwest, south, southeast, and east). The panel showing           between the background
PM2.5 concentrations from the east have the largest decreasing            pollution emissions and those
trend, which suggests the significant efforts made by industry to         originating locally from within
reduce emissions are working, especially when examining the               the airshed to determine the
change in emissions coming from the industrial sector to the east of      extent that management
the city [Jackson et al, 2017]. For more information about industry       actions can have an impact on
and partner efforts to reduce emissions, see Appendix B.                  local ambient air quality.

                                                                          PHASE 3 PLAN FINAL REPORT          14
Figure 8: Deseasonalized monthly average PM2.5 concentrations at Plaza 400 from 2005-2016 for 8 wind directions. The
centre rose diagram shows the proportion of each wind direction and PM2.5 concentration contributes to the mean
[Jackson et al, 2017]

Setting an “aspirational” target to reduce PM2.5 emissions from                                     Industry Efforts
all significant sources by 40% allowed all members of PGAIR to                                      Substantial efforts made by
reach a consensus about the type of voluntary goals that could                                      local industries operating in
be collectively achieved over various stages of effort. As PGAIR                                    the airshed have included
is not a regulatory body, the target represents a community                                         upgrades to equipment to
target, one that requires support from the community at large,                                      reduce emissions discharge.
acknowledgement that PM2.5 emissions are contributed by many                                        Both Husky Energy and
activities, and the recognition that actions from each of us as                                     Canfor Pulp Ltd. are able to
individuals are needed to achieve further air quality improvements.                                 report significant investments
Research conducted in Phase 1 and 2 identified that several major                                   in their respective systems
sources of PM2.5 within the Prince George airshed originate from                                    that show a measureable
many places including permitted and non-permitted industry,                                         difference in their discharge
commercial activities, dust, transportation and wood burning.                                       of particulate emissions.
Many of these emissions are released across the city`s landscape
making them impractical to measure on a regular basis. For this
reason, the success of the 40% emissions reduction target is
difficult to quantify. To fully evaluate this goal, the comprehensive
inventory of all air major emissions completed in Phase 2 would
need to be updated. This type of work requires significant funds
and is a lengthy process.
As a partial indicator, air emissions data available from permitted
industries (collected by ENV) was reviewed. Three approaches
were used to summarize PM emissions from permitted industrial

Approach 1:
Total emissions were calculated based on information in the air permits.
                            Amount of PM permitted to emit (as stated in permit)              # of hours permitted to operate
Permitted emissions =                                                                  X
                                                        hour                                                  year

Approach 2:
Considering that facilities may not actually operate as many hours as they are permitted to, permitted
facilities provided their actual operating hours for each year (2011-2016). These operational hours were
substituted for permitted hours.
                             Amount of PM permitted to emit (permit)               # of hours in operatation (permitee records)
Operational emissions =                                                  X
                                                 hour                                                  year
For cases where operational hours were unavailable, results from Approach #1 were substituted.
(Note: operational hours were provided for more than 90% of the total permitted emissions.)

Approach 3:
For cases where direct measurements of PM emissions are required by industrial permits (e.g. stack
testing), the measured emissions and actual operational hours were used to estimate total emissions for
each year.
                            Amount of PM emitted (stack test)             # of hours in operatation (permitee records)
Measured Emissions =                                               X
                                          hour                                                  year

                                                                                                   PHASE 3 PLAN FINAL REPORT         16
Changes of permitted PM emissions relative to 2011 (base year)

                 Approach 1: Permitted Emissions   Approach 2: Operational Emissions   Approach 3: Measured Emissions

Figure 9: Relative reductions in point source contributions (sources: ENV, PGAIR industrial members)

Stack emissions were averaged for cases where multiple tests were performed on the same stack within
the same year. For cases where measured emissions were unavailable, results from Approach #2 were
The results of all three approaches are illustrated in Figure 9. Approach 1 indicates that the total permitted
PM emissions included in permits remained consistent over the six-year evaluation period (2011-2016).
Approach 2 shows relatively small year-to-year change, with the exception of the notable reduction in
emissions in 2013. These reductions reflect changes to the operational status of permitted activities in that
particular year (e.g. facilities becoming non-operational or reducing operations to perform upgrades).
Approach 3 illustrates a consistent reduction of PM emissions throughout the Phase 3 period reaching a
reduction of 50% in 2016 (relative to 2011, the base year). This information provides some indication that
PM emissions from major point sources (e.g. industrial stacks) substantially decreased between 2011 and
2016 (~ 50 %, Figure 9). While source emission testing and permit emissions information isn’t collected in a
manner that completely answers PGAIR`s 40% reduction target, it provides an additional piece of evidence
that measureable improvements have occurred. This trend is also in agreement with the findings of the
Jackson et al. (2017) evaluation.
Some of the significant reductions to permitted PM emissions were achieved through major upgrades to
infrastructure and equipment by major emitters, and are described fully in annual member briefing notes,
available on our website ( One example is Canfor Pulp Ltd.’s upgrades at two of their
facilities within the airshed: a retrofit to the Northwood Pulp Mill #1 Recovery Boiler including installation of
an Electrostatic Precipitator; and, installation of an Electrostatic Precipitator at the Prince George #1 Power
Boiler Stack.

By air pollutant category, the following is a detailed outline of             PM10
achievements seen in the implementation of Phase 3 of the                     PM10 includes particles that
management plan.                                                              are 10 microns in diameter or
5.4.1 Dust                                                                    less which is about 1/7th the
                                                                              size of a human hair. PM10
Dust pollution levels were identified in 1995 as the top airshed              includes PM2.5 (as described
management concern because of the relationship to major health                above) as well as larger
issues identified in the research. Dust emission sources mainly               particles up to 10 microns
include ‘fugitive’ sources, meaning dust blown in from open areas,            in diameter. Particles that
on-road and off-road vehicle use, unswept parking lots, and industrial        are 2.5-10 µm in diameter
yards. The Phase 3 Implementation Plan identified two strategies to           are most often created by
focus action on dust:                                                         mechanical breakdown such
1. M
    itigate the causes of dust in areas that are not paved and at gravel     as road dust and windblown
   pit operations, construction sites, residential and commercial lots and    dust. Some types of pollen
   industry sites; and                                                        are small enough to be
2. M
    itigate dust in paved areas, in particular, roads, parking lots, and     included in PM10.
   commercial and industry sites.

 he City of Prince George introduced the Clean Air Bylaw in 2010,
which went a long way toward establishing a culture of improvement
around lot maintenance and sweeping in Prince George.

Actions taken on Dust:
PGAIR is committed to making continued improvements in reducing
the impact of dust on our air quality. The following are actions taken
by PGAIR member agencies:
• P
   GAIR produced a video called Keeping the Dust Down, offering
  some practical steps to reduce dust kicked up by certain activities.
  The video features Airiana, our air quality ambassador helping friends
  and neighbours to understand how their actions create an air quality
  problem, along with simple ways to prevent it. The video is shared on
  YouTube, on the PGAIR website and Facebook page. The video, which
  was released in March 2016, has had more than 100 views.
• T
   he City of Prince George issues an annual sweeping notice to
  businesses in the city that is also posted on its website and shared
  through social media. The notice is a reminder of provisions in the 2010
  Clean Air Bylaw that require certain actions to be taken to prevent dust
  pollution during spring sweeping activities. The City of Prince George is
  a leader in using these techniques in their annual sweeping operations,
  beginning as soon as roads are snow-free in the spring.

Many of our member agencies are also making dust management a
priority at their industrial sites. For detailed information about member
contributions, see Appendix B.

                                                                              PHASE 3 PLAN FINAL REPORT       18
5.4.2 Permitted Emissions
     TRS and Odour                    Permitted emissions come from those industries that are regulated
     What is that smell? Typically,   by the Provincial government or that require an emissions permit.
     TRS or Total Reduced             Because PGAIR is a non-regulatory body, little influence can be
     Sulphur compounds produce        exerted on the permitted portion of the emissions spectrum.
     an offensive rotten egg or       However, many of the emissions permit holders are members of
     cabbage smell that can be        PGAIR, signalling a commitment to making improvements toward
     detected by humans at very       community health.
     low concentrations and can       PGAIR identified three strategies for action:
     pervade the community,
                                      1. E
                                          ncourage implementation of the off-setting policy developed by
     especially when the air is
                                         the Province’s regional office for new or expanding industry in
     calm and stable. Industrial
                                         Prince George;
     sources of TRS include pulp
     and paper mills, refineries      2. S
                                          ecure commitment for the Regional District of Fraser-Fort George
     and sewage treatment                – City of Prince George Heavy Industry Land Use Plan (suitable
     facilities. TRS compounds           development lands outside of airshed); and
     are not normally considered
                                       ncourage continuous improvement and use of “best available
     a health hazard, but they are
                                      technology” for current, expanding and new permitted industry.
     a primary cause of odours.
                                      Through their commitment to clean air, some members in the
     The Province of British
                                      permitted emitter category have made significant contributions
     Columbia currently does
                                      to improvements. In most cases, an upgrade to Best Available
     not have ambient odour
                                      Technology (BAT) helped make measureable reductions in
     objectives for TRS but
                                      emissions of small particulate, or PM2.5. Beginning in 2009, the
     uses Pollution Control
                                      Pulp and Paper Green Transformation Program offered funds to
     Objectives developed for
                                      improve the environmental performance of pulp and paper mills in
     the Forest Products Industry
                                      Canada. Prince George’s Canfor Pulp Ltd. was a recipient of funds,
     in the 1970s as an odour
                                      but extended their commitment to improvements by investing
     reference: 1-hour average of
                                      independently in upgrades to local mills.
     5 ppb and 24-hour average
     of 2 ppb.                        5.4.3 Non-Permitted Industry & Commercial
                                      The non-permitted industry and commercial category refers to
                                      the portion of the airshed emissions that come from industry
                                      and commercial establishments that do not require a permit to
                                      emit. This category includes large and small businesses such as
                                      restaurants, fabricators, commercial heating, autobody shops,
                                      building construction, gravel pits and farm operations. The types of
                                      emissions they produce include fine particulates that come from
                                      cooking, some transportation emissions, dust, and heating sources.
                                      Strategies identified in the Phase 3 Implementation Plan include:
                                      1. E
                                          ncourage the use of best available technology and best practices to
                                         reduce emissions; and
                                      2. R
                                          ecognize best practices within the commercial and industrial

                                      Engagement with the non-permitted sector is challenging since
                                      direct attribution of emissions is not available. Efforts to reduce
                                      emissions in this category will be reviewed and remain a focus
                                      of PGAIR.

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